WOODS
v.
STATE OF FLORIDA
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
Two aggravated child abuse convictions do not violate double jeopardy where they are the same in law but involve separate factual allegations, and autopsy photographs are admissible when their probative value outweighs their prejudicial effect.
[1] Multiple punishments may be imposed for distinct acts springing from successive impulses to violate a single criminal prohibition in the course of a single criminal episo…
[2] Admission of autopsy photographs in a criminal trial is within the sound discretion of the trial court, and the ruling will not be disturbed on appeal absent an abuse of…
Previewing 2 of 2 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“for double jeopardy protection to apply, most succinctly put, the offenses must be 'the same in law and in fact.'”
Court's statement of the double jeopardy standard from Trappman v. State
Antonyo Woods was convicted by jury of first-degree felony murder and two counts of aggravated child abuse by great bodily harm involving a two-year-o…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse First Degree Felony Murder cases and more on FLexlaw
FIRST DISTRICT COURT OF APPEAL
STATE OF FLORIDA
ANTONYO WOODS, Appellant,
V.
STATE OF FLORIDA, Appellee.
No. 1D2025-0345
On appeal from the Circuit Court for Leon County.
J. Lee Marsh, Judge.
June 24, 2026
PER CURIAM.
Following a jury trial, Antonyo Woods appeals his conviction and sentences for one count of first-degree felony murder and two counts of aggravated child abuse by great bodily harm. We affirm and write to address two issues.
Woods first claims that his two child abuse convictions violate double jeopardy because they charge the same offense and overlapping time periods. See Lee v. State, 258 So. 3d 1297, 1304 (Fla. 2018). But “for double jeopardy protection to apply, most succinctly put, the offenses must be ‘the same in law and in fact.” Trappman v. State, 384 So. 3d 742, 747 (Fla. 2024) (quoting Burton v. United States, 202 U.S. 344, 380 (1906)). Although the dates of the two counts overlap, and they are the same in law, the indictment makes separate factual allegations as to each count. As the Court in Trappman made clear, "multiple punishments may be imposed for distinct acts springing from successive impulses to violate a single criminal prohibition in the course of a single criminal episode." Id. at 756 (citing Blockburger v. United States, 284 U.S. 299 (1932), and Graham v. State, 207 So. 3d 135 (Fla. 2017)).
Woods next argues that gruesome and cumulative autopsy photographs of the two-year-old victim were more prejudicial than probative. See § 90.403, Fla. Stat. (2025). However, the trial judge did not abuse his discretion in determining that the probative value of the photographs outweighed their prejudicial effect. See Hampton v. State, 103 So. 3d 98, 115 (Fla. 2012) (citations omitted) ("The admission of photographic evidence of a murder victim is within the sound discretion of the trial court and its ruling will not be disturbed on appeal absent abuse.").
The State had to establish that the victim's injuries were caused by another person rather than an accident, and the injuries were sufficient to cause the victim's death or great bodily harm. The photos of the internal injuries established that the injuries and death was not an accident, and the injuries were severe. The photos of the internal injuries also helped establish their timing and that they occurred in Woods' care. Here, given the relevance, the allegedly gruesome nature of the photos did not result in unfair prejudice that outweighed the significant probative value of the photos. See Seibert v. State, 64 So. 3d 67, 88 (Fla. 2010) (photograph of murder victim's dismembered body was admissible at a murder trial because it was relevant to show premeditation, consciousness of guilt, sequence of events, and crime scene).
AFFIRMED.
LEWIS, BILBREY, and WINOKUR, JJ., concur.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Blockburger v. United States, 284 U.S. 299 (U.S. 1932)
- Burton v. United States, 202 U.S. 344 (U.S. 1906)
- Graham v. State, 207 So. 3d 135 (Fla. 2016)
- Hampton v. State, 103 So. 3d 98 (Fla. 2012)
- Seibert v. State, 64 So. 3d 67 (Fla. 2011)
- LEE v. State, 258 So. 3d 1297 (Fla. 2018)
- Dettle v. State, 384 So. 3d 742 (Fla. 2024)